Environmental Health Analysis of “Let’s Build More Housing, Detroit” Proposed Zoning Amendment

The “Let’s build more housing” zoning amendment proposes sweeping changes to the city’s zoning. In this map Pink Areas are zoned industrial corridors and the Grey Areas are currently zoned R2, but would be ‘upzoned’ to R4. https://arcg.is/1jyzDz3

1. Purpose and Context

Detroit’s proposed “Let’s Build More Housing” zoning amendment—formally the 6th General Text Amendment (approved by the City Planning Commission on September 3, 2025)—would change how and where new homes can be built across the city.

The proposal would:

  • Allow 3- and 4-unit homes by right in R2 neighborhoods (currently limited to duplexes).
  • Permit Accessory Dwelling Units (ADUs)—small backyard or attached apartments—in R2 through R6 zones.
  • Make multifamily housing by right in B2 and B4 business areas.
  • Expand loft and mixed-use housing options in commercial and light-industrial buildings.
  • Reduce parking and lot-size requirements to encourage infill housing.

City officials say these changes are meant to increase housing choices, attract new investment, and remove outdated barriers in the zoning code.

This report offers clear, factual information to help Detroiters and City Council understand how the proposal could affect residents’ rights, neighborhood health, and land-use near industry.


2. Resident Rights and Neighborhood Exposure

Detroit’s neighborhoods sit close to long-standing industrial corridors—especially along Conner, Mack, St. Jean, Mt. Elliott, and the southwest side. The proposed changes would make it easier to build new housing in or next to these areas. That creates new opportunities but also new risks.

Reduced Protection from Industrial Impacts

If housing and industry are listed as compatible in the zoning code, residents living near factories, truck yards, or recyclers would have less ability to challenge odors, dust, or noise. When people complain about pollution, companies can point to the zoning map and argue that the use is allowed there—making it harder for the City or the state to act.

Fewer Health Safeguards

State environmental rules—like Michigan’s Air Pollution Control standards—treat homes and schools as “sensitive receptors.” If zoning encourages new housing right next to industry, regulators may assume residents chose to live there and give lower priority to future enforcement or permit limits.
This shift can make it easier for existing industries to renew or expand operations without added review.

Everyday Exposure

People moving into new by-right units along busy truck corridors could experience more diesel exhaust, vibration, and noise. Without environmental or health screening, those risks aren’t measured or reduced before construction begins—putting the cost of exposure on residents instead of operators.

Limited Public Input

Because these new uses would be by right, they skip public hearings and appeals. That means neighbors would not be notified or consulted before projects are approved—removing a step that often identifies flooding, traffic, or pollution concerns early.


3. What the Proposal Changes

Lofts in Industrial Areas (Sec 50-12-159)

Allows residential units inside existing industrial or commercial buildings as conditional uses in M1–M4 zones, and by right in designated overlays.
Effect: Normalizes housing within industrial buildings, limiting future nuisance protection.

By-Right Housing in Business Districts

Adds residential use as by right in B2, B3, and B4 districts—many directly bordering industrial corridors.
Effect: Expands housing potential along freight and manufacturing routes.

Industrial District Updates

M1–M4 continue to allow heavy uses (metalwork, truck terminals, manufacturing) and now permit brewpubs, distilleries, and food processing by right.
Effect: Further mixes industrial and residential activity without new separation standards.

Overlay Expansion

Extends “Traditional Main Street” and “Gateway” overlays into older industrial corridors.
Effect: Moves Detroit from its traditional “separation of uses” model toward “coexistence.”


4. Citywide Environmental and Demographic Findings

Analysis using MiEJScreen 2024 and Detroit property data shows:

  • About 42 percent of R2 parcels are within 1,000 feet of an industrial zone or truck route, mostly on the East Side and in Southwest Detroit.
  • These tracts rank in the 80th–95th percentile statewide for diesel exhaust and asthma hospitalizations.
  • Average poverty rate: 34 percent (citywide ≈ 29 percent); median household income: $27,000 (≈ 16 percent below city average).
  • They also show the fastest property-assessment increases (2021–2024) and the highest Detroit Land Bank Authority parcel concentrations—indicators of speculation and displacement pressure.

5. Michigan Law and City Responsibility

Several state laws require Detroit to consider health and safety when it changes zoning:

LawPurposeWhy It Matters Now
NREPA Part 17 (MEPA)Prevent government actions that cause “unreasonable environmental impairment.”Allowing new homes next to known pollution sources could violate this principle if impacts rise.
Public Health Code §333.2451Requires local governments to correct conditions that threaten public health.More housing near industry means more health complaints for the City to address.
Air Pollution Control (Part 55)Separates emission sources and “sensitive receptors.”New residential receptors inside industrial buffers make enforcement harder.
Michigan Zoning Enabling Act (MZEA)Requires zoning to promote public health, safety, and welfare.A review of environmental impacts would help meet this requirement.

Together, these laws show that Detroit must look at health and cumulative exposure before finalizing major zoning changes.


6. National Examples

Chicago, Illinois (2020 – Hilco Redevelopment)

After Chicago rezoned a former coal-plant site for warehouses, a smokestack implosion blanketed Little Village in dust.
Because the area had been reclassified as “mixed use,” regulators imposed minimal fines.
Residents reported lingering respiratory problems.
Chicago Tribune (2020)
Lesson: Rezoning industrial land without health review can shift liability from polluters to residents.

Houston, Texas (2021 – Union Pacific Creosote Site)

In Houston’s Fifth Ward, a rail-yard released toxic creosote for decades.
After nearby parcels were rezoned for housing, the company argued that new residents had “come to the nuisance,” limiting cleanup liability.
EPA later confirmed elevated cancer rates.
EPA Region 6 Record (2021)
Lesson: Zoning that mixes housing and heavy industry weakens residents’ rights to seek protection later.

Los Angeles, California (2017 – Boyle Heights Corridor)

After LA created its “Clean Up Green Up” zones, some recyclers claimed “non-conforming use” rights to avoid stricter air rules.
Los Angeles Times (2017)
Lesson: Even well-intended reforms can backfire if zoning language gives polluters new loopholes.

Minneapolis, Minnesota (2023 – 2040 Plan Upzoning)

Residents sued, saying the city failed to study environmental effects of its citywide upzoning.
A state court agreed and temporarily stopped the plan.
Star Tribune (2023)
Lesson: Cities must analyze environmental impacts before approving sweeping zoning changes.

Providence, Rhode Island (2022 – Port Expansion)

Zoning that allowed more mixed industrial use near the port increased truck traffic through residential streets.
Residents filed a complaint, and EPA required new mitigation steps.
Providence Journal (2022)
Lesson: Local zoning can trigger federal review when it raises cumulative pollution burdens.


7. What the Data Suggest

Detroit’s proposed ordinance would not rezone industrial land, but it would invite more residential development into areas already affected by heavy use and traffic.
That change could:

  • Increase the number of people exposed to diesel and industrial emissions.
  • Make it harder to enforce existing pollution rules.
  • Raise property values in high-burden areas before affordable housing is built, increasing displacement risk.

These are manageable risks—but only if Council adds tools that recognize them.


8. Policy Recommendations

City Council could strengthen the proposed ordinance before adoption by asking staff to explore the following actions:

  1. Set a Transition Buffer Standard
    Establish a measurable buffer—likely in the 100- to 200-foot range—between new housing and active industry.
    Use landscaping, walls, or tree lines to cut noise and diesel exposure.
  2. Add an Environmental-Health Review Step
    Require a short checklist for projects within 1,000 feet of industry or major truck routes.
    Use data from MiEJScreenEGLE MiEnviro, and the Detroit Health Department.
  3. Improve Public Notice and Disclosure
    Require developers converting industrial buildings to homes to notify residents of nearby emission sources and truck activity.
  4. Pair Up-Zoning With Stability Measures
    Expand homeowner and renter protections through HOPEPAYS, and Right-to-Counsel support in rezoned districts.
  5. Map Long-Term Transition Corridors
    Direct the Planning & Development Department to study where residential and industrial uses overlap most and recommend permanent buffer zones in the next Master Plan update.

These are policy directions, not drafted ordinance text.
They give Council a clear path to balance housing growth with health and neighborhood quality.


9. Conclusion

Detroit is updating its zoning for the first time in decades. The goal—more housing and simpler rules—is widely shared. But when new homes move closer to long-standing industry, the City must protect people’s right to clean air, quiet homes, and stable neighborhoods.

By adding clear buffers, short health reviews, and transparency measures now, City Council can make sure the Let’s Build More Housing ordinance delivers on both sides of its promise: more homes —and healthier, safer neighborhoods—for everyone.


Aevitas Complaint Analysis

Purpose

This analysis reviews data from the Michigan EGLE Pollution Emergency Alerting System (PEAS) to evaluate neighborhood air-quality conditions before and after the June 30, 2025 fire and shutdown at Aevitas Specialty Services Corp. (663 Lycaste St, Detroit, MI 48214). The goal is to assess how odor-complaint trends changed in the surrounding East Side corridor.

Background

Since the Aevitas fire, residents have reported noticeable improvements in neighborhood air quality, with the area no longer frequently affected by diesel and chemical odors. Building on the findings of the Legislative Policy Division (LPD) report that documented air-quality and complaint data prior to the fire, additional FOIA and data requests were submitted to better understand post-fire conditions and allow comparison between the two periods. While air-monitoring data are still being evaluated, the EGLE complaint data provide clear, independent evidence of change in community odor patterns.

Data Sources

  • Michigan EGLE Pollution Emergency Alerting System (PEAS) complaint data, 2022–2025
  • FOIA-released EGLE complaint datasets, including records through October 15, 2025
  • Study window: April 1 – October 1 of each year
  • Geographic focus: approximately one mile around 663 Lycaste Street, including adjoining streets within Detroit ZIP codes 48214, 48215, and 48207

Findings

Category2024 Baseline (Apr 1–Oct 1 2024)2025 Pre-Fire (Apr 1–Jun 30 2025)2025 Post-Fire (Jul 1–Oct 1 2025)
Aevitas-type odors (diesel / fuel / chemical / burning oil / gas / “raw egg”)14101
Paint-type odors (paint / spray / coating)1221
Other / unrelated (sewer / garbage / smoke / unknown)2898

Change after June 30, 2025:
Odor complaints consistent with Aevitas-type emissions declined by roughly 90 percent between the pre-fire and post-fire periods. Paint-related and other odor categories did not show comparable changes.

Between April and June 2025, residents within one mile of 663 Lycaste Street filed approximately ten Aevitas-type odor complaints. In the three months after the June 30 fire and shutdown, only one similar complaint was recorded — a decline of about 90 percent. Paint-related and other odor complaints remained relatively stable, suggesting that the improvement in neighborhood air quality was specific to the end of Aevitas’s operations.

Interpretation

The complaint data indicate a clear, site-specific improvement in air-quality conditions following the Aevitas shutdown. The sharp reduction in fuel- and chemical-type odor complaints aligns closely with the facility’s closure. Other odor categories, such as paint or general nuisance smells, did not change significantly. This pattern suggests that the decline in complaints was localized and directly associated with the absence of Aevitas operations, rather than broader city-wide or seasonal variations.

Policy Implications

  • Adopt and Implement the Aevitas Resolution:
    Fully enact the Detroit City Council Resolution regarding Aevitas Specialty Services, establishing clear expectations for environmental accountability and public-health protection.
  • Strengthen Oversight through Existing Regulatory Tools:
    Utilize all authorities identified in the Legislative Policy Division (LPD) report — including zoning, permitting, enforcement, and transparency mechanisms — to ensure that any future operation at 663 Lycaste Street proceeds only under enhanced scrutiny and enforceable compliance standards.
  • Mandate Real-Time Air Monitoring:
    Require installation of continuous fence-line monitoring for volatile organic compounds (VOCs), benzene, and related pollutants as a pre-condition to any restart or new permit issuance. Monitoring data should be publicly accessible in real time to ensure accountability.

Conclusion

The complaint data show a clear and measurable trend: after Aevitas Specialty Services ceased operations, odor complaints from the surrounding neighborhoods dropped by approximately 90 percent. This decline aligns with the facility’s shutdown and suggests that its operations were a significant factor in local odor and air-quality conditions. These findings support stronger oversight, continuous real-time monitoring, and strict accountability requirementsbefore any future industrial activity is permitted at 663 Lycaste Street.

Data Sources

EGLE FOIA Complaint Dataset (through October 2025)

EGLE PEAS Complaint Database (2022 – 2025)